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9 January 2001 External T.I. 1999-0011405 - foreign affiliates - deemed active -- attach -- Subparagraph 95(2)(a)(i)

9 January 2001 External T.I. 1999-0011405 - foreign affiliates - deemed active -- attach -- Subparagraph 95(2)(a)(i)

factoring of sister Opco receivables

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